Application of Combined Reporting, Allocation Rules Vary by State, Impose New Burdens on Non-U.S. Companies

The Bloomberg BNA Tax Management Weekly State Tax Report filters through current state developments and analyzes those critical to multistate tax planning.

An increasing number of states are requiring combined reporting as they look to combat income shifting across state lines. These changes often impose new requirements on non-U.S. corporations, including some that are not subject to federal tax. In this interview, Dennis Rimkunas of Jones Day answers questions about how the states approach allocation and apportionment issues affecting non-U.S. companies, including their different applications of the so-called 80/20 analysis and specific rules for “tax haven companies.”